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Tan Hai Peng Micheal and another (as the executors of the estate of Tan Thuan Teck, deceased) v Tan Cheong Joo and others

Court
General Division of the High Court of Singapore
Jurisdiction
Singapore
Decided
2026-03-06
AI tool
Implied
Outcome
Personal costs orders of SGD 5,000 each against the two solicitors, Mr Goh and Mr Sidhu, totaling SGD 10,000; the court also prohibited them from passing those costs to the defendants.
Monetary penalty
1

What was hallucinated

Fabricated: Case Law | Case A was a non-existent authority created by pairing a genuine case name with the neutral citation of a different real case; the court noted that the name and citation were individually real but did not belong together, and the case did not support the asserted legal proposition. || Fabricated: Case Law | Case B was entirely fictitious: neither its case name nor neutral citation corresponded to an existing case, and it did not support the legal proposition for which it was cited.

Details

Defendants’ closing submissions cited two fictitious authorities, referred to by the court as Case A and Case B. Case A combined a real case name with the neutral citation of a different case, while Case B was entirely fictitious; neither supported the propositions for which it was cited. The issue was identified by the claimants, and the solicitors admitted failing to verify the authorities, although neither confirmed which AI tool, if any, had been used. The court held that both solicitors acted improperly, unreasonably, and negligently, and imposed separate personal costs orders of $5,000 each, emphasizing their non-delegable duties to verify authorities and protect the administration of justice.

Sanction teardown · General Division of the High Court of Singapore, Singapore · 2026-03-06

Tan Hai Peng Micheal and another (as the executors of the estate of Tan Thuan Teck, deceased) v Tan Cheong Joo and others

What happened

In General Division of the High Court of Singapore, Singapore, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Case A was a non-existent authority created by pairing a genuine case name with the neutral citation of a different real case; the court noted that the name and citation were individually real but did not belong together, and the case did not support the asserted legal proposition.
  • Fabricated (Case Law)
    Case B was entirely fictitious: neither its case name nor neutral citation corresponded to an existing case, and it did not support the legal proposition for which it was cited.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Personal costs orders of SGD 5,000 each against the two solicitors, Mr Goh and Mr Sidhu, totaling SGD 10,000; the court also prohibited them from passing those costs to the defendants. (monetary penalty: 1 .)

Additional detail

Defendants’ closing submissions cited two fictitious authorities, referred to by the court as Case A and Case B. Case A combined a real case name with the neutral citation of a different case, while Case B was entirely fictitious; neither supported the propositions for which it was cited. The issue was identified by the claimants, and the solicitors admitted failing to verify the authorities, although neither confirmed which AI tool, if any, had been used. The court held that both solicitors acted improperly, unreasonably, and negligently, and imposed separate personal costs orders of $5,000 each, emphasizing their non-delegable duties to verify authorities and protect the administration of justice.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/3070/2026_SGHC_49.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/3070/2026_SGHC_49.pdf

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